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determination with respect to the multiple excuses for their
inability to attend a hearing. Petitioners did not present any
proposal for payment of the unpaid balance of their tax liability
for 1998, other than an offer in Court that Ms. Pless would pay
$500 toward the balance. Petitioners never supplied the
financial information requested in the Appeals officer’s letter
of June 13, 2001.
Ms. Pless failed to present evidence that she would qualify
for relief from joint and several liability or any evidence
contradicting the tax auditor’s findings, which were adopted by
the Appeals officer. Her failure to file tax returns for years
subsequent to 1998, as well as the factors considered by the tax
auditor, are factors weighing against relief. See Rev. Proc.
2000-15, sec. 4.03(2), 2000-1 C.B. 447, 449.
On consideration of the entire record, we conclude that
petitioners were provided several opportunities for a hearing
contemplated by section 6330, they failed to take advantage of
that opportunity, and they engaged in dilatory conduct to
postpone collection. Moreover, we conclude that, even if the
evidence that they offered at trial of this case had been offered
at a hearing, the determination would have been the same. Thus,
we conclude that there was no abuse of discretion in denying
Ms. Pless’s claim for relief under section 6015(f) or in
determining that the proposed collection action could proceed
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